Attachment STA Request

This document pretains to SAT-STA-20130102-00003 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2013010200003_979619

January 2, 2013


Ms. Marlene H. Dortch
Secretary
Federal Communications Commission
445 12th Street, S.W.
Washington, DC 20554

Re:    Request for Further Extension of Special Temporary Authority to Drift
       and Operate Intelsat 8 (Call Sign S2460)

Dear Ms. Dortch:

Intelsat License LLC ("Intelsat") herein requests an additional 60 days—from
January 7, 2013 through March 5, 2013—of the Special Temporary Authority
(“STA”)1 previously granted Intelsat to drift Intelsat 8 (call sign S2460) from
166.0° E.L. to 169.0° E.L. and operate at 169.0° E.L.2 Intelsat 8 is currently
operating at 169.0° E.L.3

At 169.0° E.L., Intelsat will continue to utilize the specific TT&C frequencies
below:



1
  Intelsat has filed its STA request, an FCC Form 159, an $860.00 filing fee and
this supporting letter electronically via the International Bureau’s Filing System
(“IBFS”).
2
  See Policy Branch Information; Actions Taken, Report No. SAT-00914, File
No. SAT-STA-20121105-00191 (Nov. 30, 2012) (Public Notice); Policy Branch
Information; Actions Taken, Report No. SAT-00896, File No. SAT-STA-
20120815-00132 (Sept. 7, 2012) (Public Notice). Intelsat has filed an
amendment to its pending application to modify the Intelsat 8 license to seek
redeployment and operational authority at 169.0º E.L. rather than 169.1° E.L.
See Policy Branch Information; Satellite Applications Accepted for Filing, File
Nos. SAT-AMD-20120815-00131 (Sept. 7, 2012) and SAT-MOD-20120619-
00100 (July 20, 2012) (Public Notice).
3
  The end of life of Intelsat 8, assuming the drift and station-kept operations, is
expected to be May 2019. The January 2014 end of life projection for Intelsat 8
listed in Intelsat’s 10-K filing is the estimated end of service life. See Annual
Report Pursuant to Section 13 or 15(d) of the Securities Exchange Act of 1934,
For the fiscal year ended December 31, 2011, Intelsat S.A. (Mar. 1, 2012)
available at http://www.intelsat.com/_files/investors/financial/2011/Q4-2011-
Intelsat-Form10K.pdf. The service life is a more conservative estimate that may
be adjusted subsequently to reflect potential fuel life based on the health of the
satellite.


Ms. Marlene H. Dortch
January 2, 2013
Page 2


Uplink:

13998.0 MHz (RHCP)

Downlink:

12747.0 MHz (H)
12748.0 MHz (V)

12747.0 MHz (LHCP)
12748.0 MHz (RHCP)

At 169.0° E.L, Intelsat will continue to use the communications frequencies
below:

Uplink:

5925 – 6425 MHz
14000 – 14500 MHz

Downlink:

3700 – 4200 MHz
12250-12750 MHz

Grant of this STA extension request is in the public interest because it will allow
Intelsat to expand customer services at the 169.0° E.L. location. In addition,
grant will allow the FCC additional time to process the pending application for
permanent authority to operate Intelsat 8 at 169.0º E.L.

Grant of this STA extension request will not result in increased risk of harmful
interference. Intelsat will continue to operate Intelsat 8 at 169.0° E.L. in
accordance with its coordination agreements governing the location.

Intelsat has assessed and limited the probability of the space station becoming a
source of debris as a result of collision with large debris or other operational
space stations. Intelsat 8 will not be located at the same orbital location as
another satellite or at an orbital location that has an overlapping station-keeping
volume with another satellite. Further, Intelsat is not aware of any other FCC
licensed system, or any other system applied for and under consideration by the
FCC, having an overlapping station-keeping volume with Intelsat 8 at 169.0°
E.L. Finally, Intelsat is not aware of any system with an overlapping station-


Ms. Marlene H. Dortch
January 3, 2013
Page 3


keeping volume with Intelsat 8 at 169.0° E.L. that is the subject of an ITU filing
and that is either in orbit or progressing towards launch.

Intelsat also requests that the waiver previously granted Intelsat 8 of Section
2.106 with respect to use of the 12250—12750 MHz frequency band on a non—
interference, non—protected basis in ITU Region 2 continue to apply at 169.0°
ELA
For the reasons set forth herein, Intelsat respectfully requests that the
Commission expeditiously grant this extension request.

Sincerely,



OJA@;&
Susan H. Crandall
Assistant General Counsel
Intelsat Corporation


ce: Stephen Duall
    Jay Whaley
    Cindy Spiers




* See Policy Branch Information; Actions Taken, Report No. SAT—00896, File
No. SAT—STA—20120815—00132 (Sept. 7, 2012) (Public Notice). See also
PanAmSat Licensee Corp. Application for Modification ofAuthority to Operate
the PAS—5 Satellite at the 166° E.L. Orbital Location, Order and Authorization,
DA 06—6, File Nos. SAT—MOD—19980928—00078, SAT—AMD—19990222—00024,
SAT—AMD—20020326—00055, SAT—STA—20020705—00097, and SAT—AMD—
20051116—00220, 21 FCC Red 36, 1 (Jan. 4, 2006). The Intelsat 8 satellite
previously was known as PAS—5.



Document Created: 2013-01-02 16:49:39
Document Modified: 2013-01-02 16:49:39

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